National Coalition Against Parental Alienation

Promoting Awareness and Solutionssm

Kasten v. Kasten:

[UNPUBLISHED]

Alienating Parent: ♂

“The record also contains evidence that appellant has rejected any concept that his daughters’ ‘emotional development requires a positive relationship with both parents.’ In addition, appellant’s ‘negative feelings’ outweigh his ability to support a positive relationship for his children with their mother. Furthermore, appellant seemed to have little understanding of the effect his feelings towards appellee might have on the girls’ feelings about their mother. In observing that Lori was openly hostile toward and alienated from her mother, one expert also noted that Lori made statements glorifying her father, a pattern of polarization which could very well develop in Jaime if appellant is granted custody of both children.”
Kasten v. Kasten, 1987 WL 20378 at *6 (Ohio App.) (concurring opinion).

Sims v. Hornsby:

[UNPUBLISHED]

Notes: Father accused mother of PAS, but evidence of it was “not persuasive.” Father’s assignment of error overruled, judgment of trial court affirmed, custody to remain with mother.

“Appellant’s expert witness was Dr. Roger H. Fisher, a clinical psychologist. Dr. Fisher testified that appellee’s behavior toward Heather exhibited symptoms of ‘parental alienation syndrome.’”
Sims v. Hornsby, 1992 WL 193682 at *1 (Ohio App. 12 Dist.).

Zigmont v. Toto:

Alienating Parent: ♀

“Seven psychologists have evaluated the parties and their children. They determined that this protracted litigation had a detrimental effect on the parties and their children. Appellant loves his children and they love their father. Nonetheless, the children suffered from ‘Parental Alienation Syndrome,’ which was further compounded by the parties’ inability to communicate. Furthermore, the children have too much input in how they relate to their father. The psychologist agreed and recommended that Appellee have sole parental control and that psychological therapy continue with a single therapist with the ultimate goal of bettering the relationship between the children and Appellant.”
Zigmont v. Toto, 1992 WL 6034 at *2 (Ohio App. 8 Dist.).

Conner v. Renz:

[UNPUBLISHED]

Notes: Custodial parent did not change. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“As part of an agreed entry, the parties and their children were to undergo counseling with a therapist, Bette Gillman. When Ms. Gillman reported that she believed the underlying problem was parental alienation syndrome, i.e., that Conner was attempted to alienate the children from their father and his family, Conner sought to have her removed as the therapist.”
Conner v. Renz, 1995 WL 23365 at *1 (Ohio App. 4 Dist. 1995).

State v. Koelling:

[UNPUBLISHED]

Notes: Custodial parent did not change. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“Dr. Jolie Brams, a political psychologist specializing in children and families, testified on behalf of defendant as to ‘parental alienation syndrome,’ a syndrome described as the skewing of children’s behaviors, attitudes and perceptions because of tensions and loyalty conflicts within a family. In other words, children in families where loyalty conflicts exist tend to side with one parent, oftentimes alienating the other. Dr. Brams maintained that this syndrome is particularly common in cases of child custody and in situations where there are allegations of sexual abuse within the family. Dr. Brams further stated that children who are subject to parental alienation syndrome are often vulnerable to a therapist’s reinforcement that one parent is considered ‘bad.’”
State v. Koelling, 1995 WL 125933 at *6 (Ohio App. 10 Dist.).

Arthur v. Arthur:

Notes: Custodial parent did not change. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“The matter proceeded to trial. At trial, Dr. John Mason, the court-appointed psychologist, reiterated the concerns he voiced in his report to the trial court regarding the children’s attendance at the Academy, which, he opined, shielded them from the real world. Mason testified, while in wife’s custody, the children’s outside contacts were limited to church members. Due to the lack of cooperation between husband and wife, Mason recommended shared parenting in order to avoid the development of parental alienation syndrome.”
Arthur v. Arthur, 130 Ohio App.3d 398, 403, 720 N.E.2d 176 (Ohio App. 5 Dist. 1998).

Beatley v. Block [I]:

[UNPUBLISHED]

Notes: Custodial parent did not change. The expert evaluated for parental alienation and testified but found no evidence to support parental alienation.

“The facts concerning parental alienation were well known to both Dr. Virgil and to the court at the time of the original judgment, as the judge speaks extensively to such factors in the original order. In addition, Dr. Virgil had testified at the original hearing regarding the issue of parental alienation. Dr. Virgil’s alleged new testimony on parental alienation is not a change of circumstances, but merely a modified opinion on an issue discussed just months earlier.”
Beatley v. Block, 2000 WL 492127 at *2 (Ohio App. 5 Dist.).

Beatley v. Block [II]:

[UNPUBLISHED]

Alienating Parent: ♂♀

“The court attempted to deal with the parental alienation issue by ordering all parties into counseling. The court did not abuse its discretion in naming appellee the residential parent, as there was evidence of both parties engaging in alienation.”
Beatley v. Block, 2000 WL 699653 at *2 (Ohio App. 5 Dist.).

Pathan v. Pathan:

[UNPUBLISHED]

Alienating Parent: ♀

“Dr. Richard Gardner was appointed for the limited purpose of determining if Sabina suffered from ‘parental alienation syndrome’ (PAS)resulting from conduct of either parent intending to cause Sabina to fear or despise the other parent, or to otherwise cause damage to the relationship between Sabina and the other parent.”
Pathan v. Pathan, 2000 WL 43711 at *4 (Ohio App. 2 Dist. 2000).

Bates v. Bates:

[UNPUBLISHED]

Notes: Experts disagreed regarding a finding of parental alienation.

“The psychologists reached different evaluations of the Bates family, each favorable to their respective client. The doctors disagreed on whether parental alienation syndrome existed in the family.”
Bates v. Bates, 2001 WL 1560915 at *2 (Ohio App. 11 Dist.).

Doerman v. Doerman:

[UNPUBLISHED]

Alienating Parent: ♀

“At the hearing, Dr. Dix testified that when she was treating the family, Mrs. Doerman demonstrated a moderate level of parental alienation syndrome.”
Doerman v. Doerman, 2002 WL 1358792 at *6 (Ohio App. 12 Dist.).

Fetty v. Fetty-Omaits:

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“The trial court’s determination was to the effect that the remarriage triggered parental alienation and therefore constituted such required sufficient change in circumstances. While an argument may be made that the expert was insufficiently qualified to testify as to conclusions in this terminology (T. at p. 89-97, 678 N.E.2d 541), it is abundantly clear that the facts, as accepted, support this determination, regardless of the terminology or semantics selected.”
Fetty v. Fetty-Omaits, 2003 WL 302399 at *5 (Ohio App. 5 Dist.).

In re S.G.:

[UNPUBLISHED]

Alienating Parent: ♀

“Dr. Ezzo also testified. Ezzo stated appellant had been the only party to cooperate in completing a psychological evaluation. Ezzo found no indications that limited appellant’s ability effectively to parent S.G. Ezzo found, however, on the G. family’s part a ‘campaign of denigration’ of appellant. This pattern indicated the existence of ‘parental alienation syndrome.’ Ezzo stated the syndrome causes ‘damage’ to children.”
In re S.G., 2003 WL 125122 at *4 (Ohio App. 8 Dist. 2003).

Schottenstein v. Schottenstein:

[UNPUBLISHED]

Alienating Parent: ♀

“The trial court found that the evidence presented demonstrated that appellant had permitted absenteeism from school, undermined the girls’ relationship with, and alienated them from, appellee, obstructed appellee’s regular parenting time, caused the girls to become overly identified with and involved in appellant’s problems and concerns, particularly Sarah, who is ‘enmeshed’ with appellant.”
Schottenstein v. Schottenstein, 2003 WL 22176786 at *13 (Ohio App. 10 Dist. 2003).

Bechara v. Essad:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody to target parent: ♀

“The Court is deeply troubled by Plaintiff/Father’s actions. In fact, Dr. Lynn Ross DiMarzio testified that withholding a child from a parent is a form of parental alienation, to which this Court highly frowns upon.”
Bechara v. Essad, 2004 WL 1325636 at *5 (Ohio App. 7 Dist.).

In re T.M.:

Alienating Parent: ♀

“[T]he psychologist expressed concerns with the ‘parental alienation dynamics’ in this case. He found that the four children living with the mother have been influenced in their attitudes and feelings towards their father by the fear and anger that the mother has towards him.”
In re T.M., 161 Ohio App.3d 638, 642, 831 N.E.2d 526 (Ohio App. 12 Dist. 2005).

Curie v. Curie:

[UNPUBLISHED]

Alienating Parent: ♀

“In this Court’s Judgment Entry of August 4, 2004, the Court noted that Dr. Eileen Leininger informed the Court that there was strong evidence of parental alienation syndrome of the children towards their father, the Plaintiff, while they have been with the Defendant, who is the residential parent and legal custodian of the children.”
Curie v. Curie, 2006 WL 3350734 at *2 (Ohio App. 11 Dist. 2006).

Horning v. Wolf :

[UNPUBLISHED]

Alienating Parent: ♀ — Custody to target parent: ♂

“Based on MMPI results [the child] Daisy shows indications of Parental Alienation Syndrome. Apparently, [the mother] Gidget would not facilitate any relationship between Daisy and her father absent the court’s intervention. . . . Dr. Milsaps-Linger, who conducted a parental alienation evaluation for the trial court, stated in her report that appellant’s responses to the Minnesota Multiphasic Personality Inventory—2 test ‘resulted in a profile the indicated significant mental health issues’ and that appellant had a ‘tendency toward hypochondriasis.’ She further opined that appellant’s general profile suggested a ‘mixed affective disturbance’ and that appellant’s ‘current level of day-to-day coping and self-sufficiency appears uneven and disorganized.’ In short, from our review of the trial court’s November 4, 2005 Judgment Entry, it is apparent that the trial court considered all of the best interest factors set forth in R.C. 3109.04(F) . . . [T]he trial court . . . clearly found that, based on consideration of all of the factors, it was in Daisy’s best interest for custody to be granted to [the father].”
Horning v. Wolf , 2006 WL 3505864 at *4 (Ohio App. 5 Dist. 2006).

Seitz v. Seitz:

[UNPUBLISHED]

Alienating Parent: ♂ — Custody to target parent: ♀

“Through all the parental alienation exhibited by the Plaintiff, the Defendant appears to bear no animosity toward the Plaintiff. The children will have an opportunity to grow in the new environment with the Defendant.”
Seitz v. Seitz, 2007 WL 80039 at *6 (Ohio App. 5 Dist.).

Walton v. Walton:

[UNPUBLISHED]

Alienating Parent: ♀

“Brenda used the allegations of physical abuse, not just in support of her position in court, but also as a justification for her clearly concentrated effort to alienate her sons against Philip. Among the ways in which she interfered with Philip’s relationship with the boys were her repeated refusals to allow Philip his turn in court-ordered parenting rotations. In addition, Brenda purchased and permitted the boys to install key-locks on their bedroom doors in order that the boys could avoid meals and other contact with Philip during those times he was in charge . . . [C]ourt-appointed custody evaluator, psychologist Dr. Wayne Graves . . . observed: ‘[M]other’s psychological status is so dysfunctional that I do not see any remediation possible within any short term time frame as within several years of intense psychological assistance. I do not expect change to occur there so that she could become by some rehabilitation primary parental responsibility.’”
Walton v. Walton, 2007 WL 2405329 at *2 (Ohio App. 6 Dist.).

Hamilton v. Hamilton:

[SLIP COPY]

Alienating Parent: ♀

“Dr. Douglas Darnell, a licensed psychologist testified. Dr. Darnell met with Mr. Hamilton 2 times and reviewed information provided to him by Mr. Hamilton . . . Dr. Darnell stated he found it reasonable to conclude that these children suffered from parental alienation syndrome. He noted that the longer this alienation occurs the more likely it will damage their global adjustment.”
Hamilton v. Hamilton, 2008 WL 2861705 (Ohio App. 2 Dist. 2008).

Truex v. Truex:

Alienating Parent: ♀

“The trial court expressed serious concerns about Dawn’s failure to cooperate with Dr. Millsaps-Linger regarding parental-alienation syndrome.”
Truex v. Truex, 179 Ohio App.3d 188, 191, 901 N.E.2d 259 (Ohio App. 5 Dist. 2008).

In re J.M.:

[SLIP COPY]

Alienating Parent: ♀

“While he could not state to a certainty that the children’s negative attitude toward Charles was due to PAS, Dr. Colina did testify regarding the possible effect PAS could have on the children in the long-run. However, the juvenile court also considered Dr. Early’s report regarding PAS, and whether Ann Marie was the source of the children’s negative relationship with Charles. . . . In her report to the court, Dr. Early sets forth her findings after noting that the purpose of the children’s therapy was to ‘assess the degree to which the effects, if any, of parental alienation have influenced the relationship between the children and their father, Charles [M].’”
In re J.M. (Slip Copy), 2009 WL 2929300 at *8 (Ohio App. 12 Dist.).

Lisboa v. Lisboa:

[SLIP COPY]

Alienating Parent: ♂

“Our review of the evidence supports the trial court’s findings. The record contains Kimberly’s and the GAL’s testimony relating to Jose’s attempts to alienate the child from her mother.”
Lisboa v. Lisboa (Slip Copy), 2009 WL 3155135 at *3 (Ohio App. 8 Dist.).

Rice v. Lewis:

[SLIP COPY]

Alienating Parent: ♀ — Custody to target parent: ♂ (but on appeal, basis in PAS found to be abuse of discretion)

“Lewis saw Licensed Professional Clinical Counselor Tracy Toward (hereinafter ‘Toward’) on February 12, 2008. It was the first time she had seen a counselor, psychologist, or psychiatrist during the proceedings. Lewis claimed that she had a hard time finding professionals equipped to deal with Manchausen Syndrome by Proxy or Parental Alienation Syndrome. . . Toward testified that Lewis did not have either Munchausen Syndrome by Proxy or Parental Alienation Syndrome.”
Rice v. Lewis, 2009 WL 1027544 at *3 (Ohio App. 4 Dist. 2009) (emphasis added).

Weisgarber v. Weisgarber:

[SLIP COPY]

Alienating Parent: ♀

“In the third assignment of error, Mother maintains the trial court erred in finding a change of circumstances in July 17, 2007. . . . Specifically, Mother notes the trial court’s reliance on the report of Dr. Millsaps-Linger, without requiring she testify or be made available for cross-examination. . . . The following exchange occurred at the January 27, 2006 hearing during the testimony of the guardian ad litem, Attorney John Frank: Q. Okay. I will just be referencing it as Dr. Patricia Milsaps-Linger’s report so that it’s not put into the record except under seal. Can you tell me what you gleaned from her report. A. A number of things, first of all, she feels that there is definitely parental alienation,I believe, if I can remember, the text of her letter, I believe that she said that seven of the eight identifying factors of PAS or parental alienation syndrome were present in Alexis, that’s the oldest child . . . she felt that the prognosis for Monica’s redemption or recovery from parental alienation syndrome,I believe to use her word, was poor. . . . Mother did not object to the testimony of Attorney Frank or to the introduction of the report of Dr. Millsaps-Linger. Therefore, any alleged error is waived.”
Weisgarber v. Weisgarber, 2009 WL 27339 at *3-4 (Ohio App. 5 Dist. 2009).

Rooney v. Rooney:

[SLIP COPY]

Alienating Parent: ♀ — Custody to target parent: ♂

“Dr. Mark Tully, a psychologist and a forensic evaluator in child custody cases, testified [that] Mother had engaged in parental alienation. . . . The doctor discussed parental alienation and the negative effects it has on the child’s relationship with the parent being alienated as well as the child’s future relationships with others. Dr. Tully noted research has shown traditional therapy does not work in parental alienation cases, and the only solution in the instant matter was a change of custody. In his opinion, a change of custody of the children would be less harmful to them than the continued alienation. . . . Dr. Robyn Tener was also called to testify. Like Dr. Tully, she defined the term ‘parental alienation.’ Dr. Tener noted Mother did not want the children to have a positive perception of Father. The doctor acknowledged Father had said and done inappropriate things, however, Mother’s conduct was much more pervasive. Dr. Tener rated the degree of alienation as moderate. . . . Dr. Tener discussed how parental alienation affects children. [Held: trial court did not abuse its discretion in terminating mother and father’s shared parenting plan and naming father as the residential and custodial parent of the parties’ two youngest children.]”
Rooney v. Rooney, 2010 WL 2186026 at **2, 3 (Ohio App. 5 Dist.).

Flowers v. Flowers:

[SLIP COPY]

Alienating Parent: ♀

“The trial court expressly stated, ‘[w]hile [appellant’s] position appears on its face logical and reasonable it completely glosses over the fact that the GAL’s involvement in this case is largely necessitated by [her] blatant and repeated acts of parental alienation.’”
Flowers v. Flowers, 2011 WL 5825404 at *6 (Ohio App. 10 Dist. 2011).

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